habitats regulations screening assessment - oct 2012

7/29/2019 Habitats Regulations Screening Assessment - Oct 2012

1/111

MANSTON AIRPORT

MANSTON AIRPORT,PROPOSED NIGHT-TIME FLYING POLICY

Habitats Regulations Screening Assessment

October 2012ECO2995.Hab Regs As.dv5


2/111

COPYRIGHT

The copyright of this document remains withAspect Ecology. The contents of this documenttherefore must not be copied or reproduced inwhole or in part for any purpose without the

written consent of Aspect Ecology.

PROTECTED SPECIES

This report may contain sensitive informationrelating to protected species. The informationcontained herein should not be disseminatedwithout the prior consent of Aspect Ecology.

LEGAL GUIDANCE

The information set out within this report in noway constitutes a legal opinion on the relevantlegislation. The opinion of a legal professionalshould be sought if further advice is required.

Aspect Ecology LtdHardwick Business Park

Noral WayBanbury

OxfordshireOX16 2AF

T 01295 276066F 01295 265072

E [email protected]

W www.aspect-ecology.com


3/111

CONTENTS

1. EXECUTIVE SUMMARY 1

2. INTRODUCTION 4

3. LEGISLATIVE CONTEXT & HABITATS REGULATIONS ASSESSMENT PROCESS 6

4. INTERNATIONAL ECOLOGICAL DESIGNATIONS 7

5. ASSESSMENT OF LIKELY SIGNIFICANT EFFECTS 11

6. REFERENCES 23

PLANS

PLAN 2995/ECO1 Site Location

PLAN 2995/ECO2 Ecological Designations

PLAN 2995/ECO3 Distribution of Qualifying Bird Species

PLAN 2995/ECO4 Aircraft Flight Paths

APPENDICES

APPENDIX 1 Manston Airports Proposed Night-time Flying Policy

APPENDIX 2 Thanet District Councils Consultation Response

APPENDIX 3 Ecological Designations citations

APPENDIX 4 Location of current surface water discharge

APPENDIX 5 Manston Airports Bird Hazard Control Plan

APPENDIX 6 Extract of Bickerdike Allen Partners Aircraft NightNoise Assessment: Impact to Birds in Coastal Habitats


4/111

Manston Airport Night-time Flying Policy 2995.Hab Regs As.dv5Habitats Regulations Screening Assessment

OCTOBER 2012 / ASPECT ECOLOGY 1

1. EXECUTIVE SUMMARY

1.1. A proposed Night-time Flying Policy (NTFP) was submitted by Manston Airport toThanet District Council in October 2011. In its consultation response (May 2012),the Council considered that the Airport would as a competent authority need toaddress whether the proposed NTFP constitutes a plan or project under the

Habitats Regulations, and then follow the further requirements of those Regulationsas relevant.

1.2. Aspect Ecology was subsequently commissioned by the Airport to conduct aHabitats Regulations Screening Assessment to identify whether the proposal andresulting increase in night-time flights, if implemented, would be likely to have asignificant effect, on nearby international ecological designations.

Thanet Coast Special Area of Conservation (SAC)

1.3. The Airport lies approximately 3.3km south of the Thanet Coast SAC, designated onthe basis of Annex 1 reefs and submerged or partially submerged sea caves. No

habitats within the SAC will be directly physically affected by the proposals.

1.4. Pollutants such as nitrogen oxides emitted by aircraft engines can result in nitrogendeposition, which can adversely affect habitats. Implementation of the proposedNTFP would permit an increase in the number of total flights taking place atManston Airport (a maximum of 659 flights/year, which in 2018 would amount to~1.4% of the total annual flights, estimated to be 46,139), and would therefore likelycause a minor increase in the volume of pollutants produced by the airport.However, following DEFRA Guidance, given the distance involved is greater than1km, it is considered unlikely that any significant effects will arise at the SAC inrespect of NOx emissions and resultant N deposition. More importantly, the relevant

Annex 1 habitats are not considered sensitive to nitrogen.

1.5. Surface water run-off from Manston Airport currently discharges into Pegwell Bay(within the SAC), and contains low concentrations of a number of synthetic and non-synthetic compounds. However, the proposed NTFP will not result in a net increasein the volume or concentration of surface water pollutants, and in any event, plansare in development to either install an interceptor on this outfall or relocate theexisting discharge to a less sensitive area near the airport, which may in factrepresent an improvement over the existing situation.

1.6. It is therefore considered that the proposed NTFP is unlikely to have anysignificant effect on the Thanet Coast SAC.

Sandwich Bay SAC

1.7. Sandwich Bay SAC is located approximately 1km south-east of the Airport andincorporates fixed dunes with herbaceous vegetation, embryonic shifting dunes,shifting dunes with Marram Grass, dunes with creeping willow and humid duneslacks. As with Thanet Coast SAC, the primary potential impact of the proposedNTFP on the habitats of interest at Sandwich Bay is an increase in the volume ofpollutants, as there will be no direct physical impact.

1.8. The increase in the total number of permitted flights would be minimal, andaccordingly any increase in pollutants will also be very limited. Furthermore,

following DEFRA Guidance, given the distance involved is greater than 1km, it isconsidered unlikely that any significant effects will arise at the SAC in respect ofNOx emissions and resultant N deposition.

1.9. It is therefore considered that the proposed NTFP is unlikely to have any


5/111



significant effect on Sandwich Bay SAC.

Thanet Coast and Sandwich Bay SPA / Ramsar1.10. The Airport lies approximately 1km north-west of the Thanet Coast and Sandwich

Bay SPA, which supports internationally important populations of breeding Little

Tern, wintering Golden Plover, and wintering Turnstone. Consideration has beengiven to potential impacts on the qualifying bird species, including in particularcollision risk, disturbance from noise or visual presence, and light disturbance.

Collision risk

1.11. The majority of collisions of birds with aircraft take place within the immediatevicinity of the Airport. As such, Golden Plover is considered to be at most potentialrisk, as flocks of this species are known to forage extensively at night on the short-sward grassland sometimes associated with airports. In contrast, flocks ofTurnstone and Little Tern are more generally confined to the coast.

1.12. However, as part of its Bird Hazard Control Plan the Airport implements a LongGrass Policy, which will continue to keep habitats in the vicinity of the airport lessattractive to birds such as Golden Plover, and therefore minimise the risk ofcollision. Birds are also actively chased off from the runways and high-risk zonesaround the airport to further reduce the chances of collision. These techniquesappear to be effective, as only a very small number of bird collisions have beenrecorded at the airport and of these, none were Golden Plover.

1.13. A large proportion of approach and departure routes lie over Thanet Coast andSandwich Bay SPA/Ramsar. These routes coincide with areas of habitat supportingmoderate to high populations of Golden Plover, Turnstone and Little Tern, and the

majority of local wader flight-lines / migration routes also cross these areas, often atnight. On average, when aircraft arriving or departing from the Airport intersect withthe coast, they are travelling at an altitude of 2,534m, i.e. above the maximumaltitude of 2,000m that birds will ordinarily fly at, and well above the 200m that thelarge majority of waders generally fly below.

1.14. Although the frequency of flights overnight would increase if the proposed NTFPwere implemented, the flight lines and altitudes of aircraft will not be altered.Accordingly, the majority of aircraft will remain above the altitudes at which they aremost likely to encounter birds such as Golden Plover, Turnstone or Little Tern. Insummary, the collision risk posed by the NTFP is minimal, and it is thereforeextremely unlikely to result in any significant effects on the qualifying bird species.

Disturbance from noise or visual presence

1.15. Aircraft are known to disturb birds such as Golden Plover, Turnstone and Little Tern,albeit none of these species are thought to be especially susceptible and there is noevidence that noise-induced disturbance leads to population-level impacts in thesespecies. The literature suggests that at least some disturbance caused by aircraft isa result of visual cues. However, any response to visual stimuli should be lessenedovernight, as aircraft outlines will be less visible.

1.16. The predicted noise data indicates that from 0100m altitude (the altitudes at whichbirds will be stationary/slow-moving, and thus most susceptible to disturbance

effects), the predicted noise levels from individual aircraft passes at the coast, willbe between 43 and 80dB(A) SEL (Single Event Level). The frequency of flights


6/111



overnight under the proposed NTFP would be relatively low (2 flights per night 1),and any noise from these flights that reached nearby bird colonies would not becontinuous. Furthermore, the highest predicted dB level at the coast falls below thatsuggested to cause physical harm or to precipitate escape or startle responses inbirds. It is possible that some time-limited masking and behavioural or physiologicalresponses may arise, however it is considered unlikely to result in a significant effect

on the populations of qualifying bird species, given the transient and infrequentnature of the noise events.

1.17. It is also relevant to note that the proposed NTFP applies to an existing airport withbirds already exposed to over-flying aircraft. As such, it is likely that birds willalready be habituated to existing aircraft noise to a degree, and it is noted that birdnumbers at the SPA have remained relatively stable over the last 5 years.

Light disturbance

1.18. Lighting, at the relatively low levels that will be involved at Manston Airport overnightis unlikely to affect birds such as Golden Plover, Turnstone and Little Tern, and

indeed at the coast will have negligible effect.

In Combination Assessment

1.19. There are no known proposals, including Manston Airports Masterplan, that wouldappear likely to combine with the negligible effects predicted from the proposedNTFP in such a way as would result in any significant effects on Thanet Coast /Sandwich Bay SACs, or Thanet Coast and Sandwich Bay SPA / Ramsar.

Conclusion

1.20. Based on the results of the screening assessment, taking account of the nature,magnitude and scale of the proposals along with the stated conservation objectivesand known sensitivities of the habitats and species associated with the ThanetCoast SAC, Sandwich Bay SAC and Thanet Coast and Sandwich Bay SPA /Ramsar, it is concluded that the proposed NTFP is unlikely to lead to anysignificant effects on the relevant internationally important interest features.As such, it is considered that no further detailed consideration of the proposals bythe Competent Authority is required under the Habitats Regulations.

1Within the night-time quota period.


7/111



2. INTRODUCTION

2.1. Background

2.1.1. A proposed Night-time Flying Policy (NTFP) has been prepared by Manston Airportand this was provided to Thanet District Council in October 2011 as part of the

consultation process being undertaken by the Airport (see Appendix 1). In itsconsultation response (May 2012), the Council considered that the Airport would asa competent authority need to address whether the proposed Night-time FlyingPolicy constitutes a plan or project under the Conservation of Habitats and SpeciesRegulations 2010 (as amended), and then follow the further requirements of thoseRegulations as relevant (see Appendix 2).

2.1.2. Aspect Ecology was commissioned by Manston Airport in June 2012 to conduct aHabitats Regulations Screening Assessment to identify whether the proposed NTFPand resulting increase in night-time flights, if implemented, would be likely to have asignificant effect, on the following nearby international ecological designations:

Thanet Coast Special Area of Conservation (SAC);

Sandwich Bay SAC; and

Thanet Coast and Sandwich Bay Special Protection Area (SPA) and Ramsar.

2.2. Night-time Flying Policy

2.2.1. Under the current situation, night-time aircraft movements do occur atManston Airport, however these are on an ad hoc basis, and as such are of anunpredictable frequency throughout the year. On average, however, it is understoodthat these night-time flights currently amount to 1 or 2 per week; for example, a totalof 59 per annum in 2010 (see Table 1 below).

Table 1. Summary of the monthly night-time flights at Manston Airport between2010 and 2012


8/111



2.2.2. The proposed Night-time Flying Policy would apply between 2300 and 0700, andwould limit the number of aircraft movements to 659 per annum (between 2330 and0600), whilst the type of passenger and freight aircraft used between 2300 and 0700is limited to those that produce below a certain level (QC 42) of noise, with a cappedannual noise quota (annual quota count not to exceed 1593). The number of night-time flights that would be permitted under the proposed Night-time Flying Policy

therefore represents an increase compared to current levels, albeit these arepresently unregulated, and the night-time flights would represent a relatively smallproportion (1.4%) of the airports total predicted movements for 2018 (46,139).

2.2.3. The predicted average number of aircraft movements per night (between 2300 and0700) during 2018 is estimated by the Airport to be 8.2, split between Passenger(6.2) and Freight (2).

2.2.4. No new infrastructure is required to be built to accommodate the increased night-flying activities, and the existing routes used by aircraft will remain unaltered.

2In 1993 the Quota Count system was introduced based on aircraft noise certification data. Each aircraft type is classified and

awarded a quota count (QC) value depending on the amount of noise it generated under controlled conditions. The quieter theaircraft the smaller the QC value. Aircraft are classified separately for landing and take-off. Aircraft are divided into seven QC

bands from 0.25 to 16. Airports operating the system have a fixed quota and as each night-time aircraft movement takes

place, an amount of this quota is used up depending on the classification of the aircraft. QC4 refers to an Effective Perceived

Noise (EPN) level of 96 - 98.9 dB.


9/111



3. LEGISLATIVE CONTEXT & HABITATS REGULATIONS ASSESSMENTPROCESS

3.1. Legislation

3.1.1. Thanet Coast Special Area of Conservation (SAC), Sandwich Bay SAC, and Thanet

Coast and Sandwich Bay Special Protection Area (SPA), receive protection underthe Conservation of Habitats and Species Regulations 2010 (as amended),commonly referred to as the Habitats Regulations. The Regulations transpose theEuropean Communitys Directives 79/409/EEC 1979 on the Conservation of WildBirds and 92/43/EEC on The Conservation of Natural and Semi-Natural Habitatsand of Wild Fauna and Flora into UK legislation. The Thanet Coast and SandwichBay SPA is also designated a Ramsar site, which is treated as a European Site as amatter of policy by the UK Government.

3.1.2. The Regulations impose a duty on Competent Authorities (in this case ManstonAirport), to carefully consider whether any plan or project is likely to have asignificant effect on an SAC or SPA, either alone or in combination with other plansor projects. In most circumstances permission may only be given for a plan orproject to proceed if it has been ascertained that it will not have an adverse effect onthe integrity of an SAC or SPA.

3.1.3. What may be termed a plan or project within the Habitats Regulations is not clearlydefined, however in consideration of the points set out by Thanet District Council inits consultation response (see Appendix 2), this assessment assumes that theproposed Night-time Flying Policy is considered to be a plan or project in respect ofthe Regulations.

3.1.4. Accordingly, this screening assessment considers the potential ecological

implications of Manston Airports proposed NTFP on the nearby internationalecological designations, and whether these are likely to have a significant effect onthe interest features of these sites.

3.2. Habitats Regulations Assessment Process

3.2.1. Regulation 61 of the Habitats Regulations prescribes the process to be undertakenin order to assess the effect, and subsequent implications of a plan or project oninternational ecological designations. This process is described in more detail in theODPM Government Circular 06/2005; Biodiversity and Geological Conservation Statutory Obligations and their impact within the planning system.

3.2.2. The assessment process follows a number of stages, the first of which determineswhether the plan or project is directly connected with or necessary to sitemanagement for nature conservation. If this is not the case, the second stage, oftenreferred to as Screening, assesses whether the plan or project is likely to have asignificant effect on the internationally important interest features of the site, aloneor in combination with other plans and projects.

3.2.3. If it is assessed likely that a significant effect on the internationally important interestfeatures of the site may arise from the relevant plan or project, then the third stage;a more detailed appropriate assessment should be made of the implications for thatsite in view of its conservation objectives in order to ascertain whether or not theproposal will adversely affect the integrity of the site.

3.2.4. This document assesses the plan or project according to stages one and two of theprocess outlined above, thereby concluding whether a more detailed appropriateassessment is likely to be required.


10/111



4. INTERNATIONAL ECOLOGICAL DESIGNATIONS

4.1. Background

4.1.1. Following the production of an advisory document by English Nature (now NaturalEngland) for North East Kent European marine sites under Regulation 33(2) of the

Conservation (Natural Habitats & c.) Regulations 1994, a Management Scheme wasdrawn up by English Nature in 2001, in collaboration with local councils and anumber of additional interested parties, to outline the interest features, conservationobjectives, and management plans for the North East Kent European marine sites:Thanet Coast SAC, Sandwich Bay SAC, and Thanet Coast and Sandwich Bay SPA/ Ramsar. The Management Scheme was subsequently revised in 2007, to take intoaccount, to a greater extent, how humans interact with the local ecosystem, utilisingthe Ecosystems Approach.

4.1.2. The following sections describe the interest features and conservation objectivesoutlined within the above documents, along with any known existing pressures. Thelocations of the designations are shown on Plan 2995/ECO2, with the airport itselfshown in Plan 2995/ECO1.

4.2. Thanet Coast Special Area of Conservation (SAC)

Interest Features

4.2.1. Thanet Coast SAC incorporates two Annex 1 habitats, as listed in the EU HabitatsDirective; namely reefs, and submerged or partially submerged sea caves (seeAppendix 3). Thanet Coast includes 23km of soft chalk cliffs, the presence of whichcontributes towards the suspended sediment and chalk particles within theseawater, and presents a particularly soft substrate on which the normally rare reef

communities can thrive.

4.2.2. The rapidly eroding cliffs create many formations including stacks, arches andcaves, and support a range of marine algal and lichen communities, some of whichare solely restricted to these caves.

Conservation Objectives

4.2.3. The overall conservation objective described by Natural England for the ThanetCoast SAC is to avoid the deterioration of the qualifying natural habitats and thehabitats of qualifying species, and the significant disturbance of those qualifyingspecies, ensuring the integrity of the site is maintained and the site makes a full

contribution to achieving Favourable Conservation Status of each of the qualifyingfeatures.

4.2.4. Specifically, and subject to natural change, the individual conservation objectivesset out by Natural England are therefore to maintain and restore:

The extent and distribution of qualifying natural habitats and habitats of qualifying

species;

The structure and function (including typical species) of qualifying natural habitats

and habitats of qualifying species;

The supporting processes on which qualifying natural habitats and habitats of

qualifying species rely;

The populations of qualifying species;

The distribution of qualifying species within the site.


11/111



4.2.5. In practical terms, these conservation objectives aim to restrict and manage humanactivities that may result in:

Physical loss by removal and/or smothering

Physical damage by abrasion and/or selective extraction

Toxic contamination by increased input of synthetic and/or non- synthetic compounds

Non-toxic contamination by organic and/or nutrient enrichment Biological disturbance as a result of introduction, translocation or spread of non-native

species and/or selective extraction of species

Existing Pressures

4.2.6. The reefs and caves within the SAC are subject to relatively limited existingpressures as outlined below:

Limited physical disturbance due to relatively low-scale fishing activities, andtrampling, contributing towards reef break up;

The dredging of the Ramsgate Port approach channel has significantly damaged thereef in the immediately vicinity, albeit this damage is very restricted;

The nutrient concentrations around the Thanet Coast are known to be relatively high,however this level has not changed for 25 years and it is thought that the relativelyharsh physical conditions at the site would limit algal growth and eutrophication.

4.3. Sandwich Bay Special Area of Conservation (SAC)

Interest Features

4.3.1. Sandwich Bay SAC incorporates five Annex 1 habitats, as listed in the EU HabitatsDirective; namely fixed dunes with herbaceous vegetation, embryonic shiftingdunes, shifting dunes with Marram Grass, dunes with creeping willow andhumid dune slacks (see Appendix 3).

4.3.2. Sandwich Bay includes a range of dune habitats, albeit the system is largelyinactive, and supports a range of rare and scarce floral species including the UKslargest population of Lizard Orchid Himantoglossum hircinum.


4.3.3. The overall conservation objective described by Natural England for the SandwichBay SAC is to avoid the deterioration of the qualifying natural habitats and thehabitats of qualifying species, and the significant disturbance of those qualifying

species, ensuring the integrity of the site is maintained and the site makes a fullcontribution to achieving Favourable Conservation Status of each of the qualifyingfeatures.


The extent and distribution of qualifying natural habitats and habitats of qualifyingspecies;

The structure and function (including typical species) of qualifying natural habitats andhabitats of qualifying species;

The supporting processes on which qualifying natural habitats and habitats ofqualifying species rely;

The populations of qualifying species;

The distribution of qualifying species within the site.


12/111



Existing Pressures

4.3.5. The majority of the dunes within the SAC lie within the boundaries of golf courses,and disturbance is limited to a small number of footpaths, whilst off-track usage isrestricted. In any case, dune systems such as these rely on some element ofdisturbance to maintain their successional stages.

4.4. Thanet Coast and Sandwich Bay SPA

Interest Features

4.4.1. Thanet Coast and Sandwich Bay SPA incorporates two internationally importantpopulations of species listed in Annex 1 of the Birds Directive; namely breeding Little Tern Stena albifrons andwintering Golden Plover Pluvialis apricaria, andone internationally important population of regularly occurring migratory species;wintering Turnstone Arenaria interpres(see Appendix 3).

4.4.2. Little Tern has not bred within the site for several years, however the site remains

designated for the species. In the past, Little Tern have nested in small colonies onthe shingle and sand beach at Shell Ness in Sandwich Bay, and Plumpudding onthe northern coast of the Thanet headland, and foraged for crustaceans and smallfish in shallow waters along the coast. Between 1992 and 1996, 6 breeding pairswere present (5 year average yearly total), which amounted to 0.3% of the breedingpopulation in Great Britain at the time. Current data obtained from the BTO indicatesthat between 2006 and 2011, only 3 individuals were present during the breedingseason (5 year average yearly total) (see Plan 2995/ECO3), albeit none werebreeding.

4.4.3. Golden Plover roost and forage on intertidal mud and sandflats in Pegwell Bayand Sandwich Bay, whilst their main foraging and loafing habitat is the arable fields,grazing marsh and pastures located inland. Between 1992 and 1996, 411individuals were present (5 year average yearly total), which amounted to 0.2% ofthe population in Great Britain at the time. Current data obtained from the BTOindicates that between 2006 and 2011, 3,730 individuals were present over thewintering period (5 year average yearly total) (see Plan 2995/ECO3).

4.4.4. Turnstone roost predominantly on sand and shingle beaches from Swalecliffe toPegwell Bay, although they may also roost on man-made structures, and forage onintertidal mud and sandflats, chalk shores, sandy beaches and rocky shores.Between 1992 and 1996, 940 individuals were present (5 year average yearly total),which amounted to 1.4% of the population in Great Britain at the time. Current data

obtained from the BTO indicates that between 2006 and 2011, 1,078 individualswere present over the wintering period (5 year average yearly total) (see Plan2995/ECO3).


4.4.5. The overall conservation objective described by Natural England for the ThanetCoast and Sandwich Bay SPA is to avoid the deterioration of the habitats of thequalifying species, and the significant disturbance of the qualifying species, ensuringthe integrity of the site is maintained and the site makes a full contribution toachieving the aims of the Birds Directive.


The extent and distribution of the habitats of qualifying features; The structure andfunction of the habitats of the qualifying features;


13/111



The supporting processes on which the habitats of the qualifying features rely;

The populations of qualifying features;

The distribution of the qualifying features within the site.

4.4.7. In practical terms, these conservation objectives aim to restrict and manage humanactivities that may result in:

Physical loss by smothering

Physical damage by abrasion


Toxic contamination by increased input of synthetic and/or non- synthetic compounds

Non-toxic contamination by organic and/or nutrient enrichment

Biological disturbance as a result of selective extraction of species

Existing Pressures

4.4.8. The internationally important populations of birds, and their supporting habitatswithin the SPA are subject to a number of existing pressures as outlined below:

Disturbance by walkers, and in particular dog walkers with uncontrolled dogs;

Entanglement in fishing line and other waste from activities including angling;

Limited disturbance from motor vehicles on the beach, powered watercraft, andpotentially aerial craft;

Reduction in food availability caused by seaweed removal in order to improve bathingconditions;

Habitat disturbance through the reprofiling and redistribution of shingle and sand dueto shore management;

The nutrient concentrations around the Thanet Coast are known to be relatively high,however this level has not changed for 25 years and it is thought that the relativelyharsh physical conditions at the site would limit algal growth and eutrophication.

4.5. Thanet Coast and Sandwich Bay Ramsar

Interest Features

4.5.1. Thanet Coast and Sandwich Bay SPA incorporates one internationally importantpopulation of regularly occurring migratory species; wintering Turnstone Arenariainterpres, and supports 15 British Red Data Book wetland invertebrates. Thesecomprise three species listed as endangered: Lixus vilis, Stigmella repentiella,Bagous nodulosus;two species listed as vulnerable: the moth Deltote bankiana, thedancefly Poecilobothrus ducalisand ten species listed as rare: Emblethis verasci,

Pionosomus varius, Nabis brevis, Euheptaulacus sus., Melanotus punctolineatus,Pelosia muscerda, Eluma purpurescens, Ectemnius ruficornis, Alysson lunicornis,Orthotylus rubidus(see Appendix 3).

Existing Pressures

4.5.2. The interest features within the Ramsar are subject to relatively limited existingpressures as outlined below:

Impact from water diversion or extraction;

Unspecified disturbance from human activities;

Overgrazing by domestic livestock.


14/111



5. ASSESSMENT OF LIKELY SIGNIFICANT EFFECTS

5.1. Existing Situation

5.1.1. Manston Airport is currently used for both passenger and freight aircraft departuresand arrivals. Under the current situation, the vast majority of aircraft movements

take place during the day, and indeed there is a Section 106 agreement in placewith Thanet District Council, which specifies that there should be no regular nightflying operations at the airport until a Night-time Flying Policy has been prepared bythe Airport and a copy lodged with the Council, albeit the actual number of flights iscurrently not capped.

5.1.2. As such, current night-time aircraft movements do take place, but these do notfollow a planned schedule, and are largely governed by factors such as technicalfaults and weather. The current number of night-time flights is therefore relativelylow (no more than 1 or 2 per week on average), and as an example, during 2010, atotal of 59 aircraft movements took place overnight (see Table 1).

5.1.3. The aircraft involved in current night-time flights are dominated by relatively largefixed-wing commercial airplanes, albeit smaller fixed-wing planes with limitedpassenger capacity, some of which employ wing-mounted propellers, and anumber of helicopters are also used. The annual total night-time movements in 2010involving such smaller aircraft was 24; approximately 37% of the total annual aircraftnight-time movements for that year.

5.1.4. The altitudes, angles, and direction of both approaches and departures are set outwithin the relevant approach charts, and there is currently a PreferredDeparture Runway strategy in operation, which, in combination with a NoiseAbatement Route agreement (covered within Clauses 4 and 5 respectively of the

Second Schedule within the Section 106) seeks to avoid the most dense area ofhuman settlement to the east (Thanet), and the north-west (Herne Bay) of theairport. However, it is understood that, other than these stipulations, the airspaceabove the Thanet Coast is not regulated, and therefore aircraft may, in theory, travelwherever they wish.

5.1.5. Bird-strike is a well recognised issue at airports throughout the UK, and as suchManston Airport currently employs a Bird Hazard Control Plan (see Appendix 5),which aims to minimise the risk of bird-strike at, and within the immediate vicinity ofthe airport, through strategies such as appropriate habitat management, activelychasing birds from the areas of highest risk within the airport, and monitoring landuse and bird populations within 13km of the airport.

5.2. Description of the Proposals

5.2.1. The proposed Night-time Flying Policy is designed to instigate a programme ofregular night flying operations, and cap the number of aircraft movements overnight(between 2330 and 0600) to 659 per annum. Both passenger and freight aircraft willbe used overnight, however these will be limited to those that produce noise below acertain level (QC 4) of noise, with a capped annual noise quota (QC 1593). Theuse of helicopters is also predicted to decrease by 2018, albeit a number of flightsinvolving smaller fixed-wing aircraft with wing-mounted propellers may continue.

5.2.2. The altitudes, angles and direction of both approaches and departures will remain

the same, whilst the aircraft routes over the Thanet Coast may become subject togreater regulation as the development of the airport requires the implementation ofcontrolled airspace.


15/111



5.3. Analysis of Potential Impacts on the Thanet Coast SAC under the proposals

Physical loss by removal (habitat loss) and/or smothering

5.3.1. The airport lies approximately 3.3km south of the Thanet Coast SAC (see Plan2995/ECO2). As such, no habitats within the Thanet Coast SAC will be directly

physically affected (i.e. through removal and/or smothering) by the proposals.

Physical damage by abrasion and/or selective extraction

5.3.2. As outlined above, the airport is geographically well separated from the SAC, and assuch the proposed Night-time Flying Policy will not directly impact upon it.Furthermore, the proposals will not involve any coastal activities, which might causephysical damage to the habitats within the Thanet Coast SAC, such as abrasionand/or extraction.

Non-toxic Contamination by organic and/or nutrient enrichment (e.g.Atmospheric Pollution)

5.3.3. Modern aircraft, such as those used at Manston Airport, utilise engines whichcombust fuel efficiently, and as such emissions into the atmosphere are relativelylow. Nevertheless, pollutants such as nitrogen oxides (NOx) are still emitted bythese engines, and such emissions are known to lead to nitrogen deposition, whichin turn can lead to changes in the composition of affected habitats throughprocesses such as eutrophication.

5.3.4. Implementation of the proposed Night-time Flying Policy would permit an increase inthe number of total flights taking place from and to Manston Airport (a maximum of659 flights per year, which in 2018 would amount to approximately 1.4% of the total

annual flights, estimated to be 46,139), and would therefore likely cause a minorincrease in the volume of pollutants produced by the airport. However, as outlinedabove, the Thanet Coast SAC is located approximately 3.3km north of the airport.

5.3.5. DEFRAs Technical Guidance entitled Local Air Quality Management February2009 states, in respect of NO2, concentrations fall-off rapidly on moving away fromthe source, and that beyond a distance of 1km from the source, NO2 is unlikely tomake a significant contribution to air quality. This is supported by evidence fromresearch3 that states that pollutant emissions from aircraft are typically evident ingreater volumes at ground level, and the effect of atmospheric pollution is thereforeexpected to decline with distance from the airport. Accordingly (extrapolatingguidance for NO2 to all relevant oxides of nitrogen [NOX]) given that the source of

potential pollution at Manston Airport lies at least 3.3km away from the nearest partof Thanet Coast SAC, in line with this guidance, it is considered that any air qualityeffects from aircraft at Manston Airport on habitats at Thanet Coast SAC are unlikelyto be significant.

5.3.6. Furthermore, the DEFRA Guidance describes a threshold of 10 million passengersper annum (mppa), below which the effect on air quality on the surrounding area isunlikely to be significant. According to this guidance, the number of passengerequivalents is equal to the actual number of passengers, plus the tonnes of freighttaken in planes, where 100,000 tonnes of freight is equivalent to 1 mppa. In thecase of Manston Airport, the actual number of passengers predicted for 2018 is2,296,000, whilst the amount of freight predicted for 2018 is 167,500 tonnes, which

equates to 1. 675 mppa. In total, the passenger equivalent per annum for Manston

3Anderson, B. E. et al. (2006): Hydrocarbon emissions from a modern commercial airliner, AtmosphericEnvironment, 40:19, 3601 3612


16/111



Airport in 2018 is therefore equal to 3.961 mppa, which is well below the thresholdof 10 mppa described within the DEFRA Guidance.

5.3.7. More importantly, the habitats for which the SAC is designated, i.e. reefs andsubmerged sea caves, are not considered sensitive to nitrogen (according toinformation obtained from the online Air Pollution Information System (APIS)). It is

therefore considered unlikely that any increase in pollutants caused by the proposedNight-time Flying Policy would have any significant effect on the Thanet Coast SAC.

Toxic Contamination by increased input of synthetic and/or non-syntheticcompounds (e.g. Surface run-off)

5.3.8. The surface water run-off from Manston Airport currently discharges into PegwellBay (see Appendix 4), and contains low concentrations of a number ofsynthetic and non-synthetic compounds. However, the proposed Night-time FlyingPolicy will not result in a net increase in the volume or concentration of surfacewater pollutants, and in any event, plans are in development to either install an

interceptor on this outfall or relocate the existing surface water discharge to a lesssensitive area near the airport, and away from ecological designations including theThanet Coast SAC, which may in fact represent an improvement over the existingsituation.

Biological disturbance as a result of introduction, translocation or spread of non-native species and/or selective extraction of species

5.3.9. As outlined in sections 5.3.1 and 5.3.2 above, the airport is geographically wellseparated from the Thanet Coast SAC and as such, the additional flights resultingfrom the proposed Night-time Flying Policy are unlikely to result in biologicaldisturbance as a result of introduction, translocation or spread of non-native species

and/or selective extraction of species.

Summary

5.3.10. In summary, the increase in the total number of permitted flights would be minimal(1.4% of the predicted number of flights during 2018), and accordingly any increasein pollutants will also be very limited. It is therefore considered that the Night-timeFlying Policy will have negligible impact upon the habitats within Thanet Coast SAC.

5.4. Analysis of Potential Impacts on the Sandwich Bay SAC under the proposals

5.4.1. As for Thanet Coast SAC, the primary potential impact of the proposed Night-time

Flying Policy on the habitats of interest at Sandwich Bay SAC is an increase in thevolume of pollutants, as there will be no physical habitat loss or damage, and nobiological disturbance, within the Sandwich Bay SAC located approximately 1kmsouth-east from the airport.

5.4.2. As described in more detail within the assessment in section 5.3, the increase in thetotal number of permitted flights would be minimal, and accordingly any increase inpollutants will also be very limited.

5.4.3. Air Pollution Information System (APIS) states that the critical load of Nitrogen (thethreshold above which the habitat may be significantly affected by Nitrogenpollution) for fixed dunes with herbaceous vegetation at Sandwich Bay SAC is 8-10kg N/ha/year, for humid dunes is 10 15 kg N/ha/year, and for the remaining threedune habitats is 10 20 kg N/ha/year. APIS also states that the total deposition asof 2005 is 13.86 kg N/ha/yr, which lies above the maximum critical load for fixeddunes with herbaceous vegetation, and the minimum critical load for the other four


17/111



habitats. 8.4% of this total deposition is attributed by APIS to Other transport, whichincludes aircraft take off and landing.

5.4.4. The proposed annual cap on night-time flights of 659, assuming a worst casescenario where this represents 659 additional flights, amounts to an increase incurrent (2010) flights (estimated at 18,084) of 3.6%. Again assuming a (highly

unrealistic) worst case scenario that Manston Airport is responsible for all depositionidentified by APIS as Other transport, the 659 additional night-time flights wouldcontribute an additional 0.04kg N/ha/year attributable to Manston Airport, which isless than 1% of the minimum critical load (i.e. 0.08kg N/ha/year).

5.4.5. However, in reality, Other transport contributions would emanate from a widevariety of sources of which Manston Airport would be just one. Therefore, the actualcontribution of night-time flying would be significantly less than 0.04kg N/ha/year.

5.4.6. As outlined above, APIS specifies that, with regard to pollution from aircraft, thecrucial activities are limited to aircraft taking off and landing, and it therefore followsthat APIS considers that pollution effects from other aircraft activities (i.e. normal

flying) are minimal. This is supported by evidence from research4 that demonstratesthat pollutant emissions from aircraft are typically evident in greater volumes atground level, and the effect of atmospheric pollution is therefore expected to declinewith distance from the airport. It is therefore considered that the source of potentiallocalised air quality effects from Manston Airport is limited to the runways.

5.4.7. Although Sandwich Bay SAC is 0.91km away from the nearest part of the airport (anextensive area of grassland), the active part of the airport (i.e. the runways fromwhich aircraft will be taking off and landing) is further removed (1.27km). As set outin section 5.3, DEFRA Guidance states that beyond the distance of 1km from thesource, NO2 is unlikely to make a significant contributionto air quality. Accordingly

(extrapolating guidance for NO2 to all relevant oxides of nitrogen [NOX]) given thatthe source of potential pollution at Manston Airport lies 1.27km away from thenearest part of Sandwich Bay SAC, in line with this guidance, it is consideredunlikely that any significant effects will arise on habitats at Sandwich Bay SAC inrespect of NOx emissions and resultant N deposition caused by the proposedincrease in flights at Manston Airport.

5.4.8. Further confidence in this assessment is provided by the passenger equivalent perannum for Manston Airport in 2018 falling well below the threshold described withinthe DEFRA Guidance and set out in more detail within section 5.3, in addition toTechnical Note III of Article 17 of the European Community Directive on theConservation of Natural Habitats and of Wild Fauna and Flora (which states that air

pollution is not considered a threat or pressure with regard to the five dune habitatslisted as qualifying features of the Sandwich Bay SAC), and APIS predictions inregard to the anticipated future reductions in individual aircraft emissions.

5.4.9. Furthermore, as described above, the surface water discharge, which currently runsfrom the airport to Pegwell Bay, will be either intercepted or relocated to a lesssensitive area near the airport and away from ecological designations including theSandwich Bay SAC.

5.4.10. It is therefore considered that the proposed Night-time Flying Policy is unlikely toresult in any significant adverse effects upon the habitats within Sandwich Bay SAC.

4Anderson, B. E. et al. (2006): Hydrocarbon emissions from a modern commercial airliner, AtmosphericEnvironment, 40:19, 3601 3612


18/111



5.5. Analysis of Potential Impacts on the Thanet Coast and Sandwich Bay SPAunder the proposalsPhysical loss by smothering

5.5.1. The airport lies approximately 1km north-west of the Thanet Coast and Sandwich

Bay SPA, and accordingly no habitats within the Thanet Coast and Sandwich BaySPA will be directly affected (i.e. through smothering) by the proposals.Physical damage by abrasion

5.5.2. As outlined above, the airport is geographically well separated from the SPA, and assuch the proposed Night-time Flying Policy will not directly impact upon it.Furthermore, the proposals will not involve any coastal activities, which might causephysical damage to the habitats within the Thanet Coast and Sandwich Bay SPA,such as abrasion.

Collision risk

5.5.3. According to available literature, the majority of collisions of birds with aircraftare thought to take place within the immediate vicinity of the airport (J.B.A. Rochard,1980). As such, of the three species of international importance within the SPA,Golden Plover is considered to be the species most at potential risk, as flocks of thisspecies are known to forage extensively at night on the short-sward grasslandsometimes associated with airports. Indeed, a number of Golden Plover fatalitiesdue to collision with aircraft have been recorded at airports in Europe (J.B.A.Rochard, 1980), and consequentially the Golden Plover is listed within ManstonAirports Bird Hazard Control Plan as a priority bird group in terms of risk to aircraft.In contrast, flocks of Turnstone and Little Tern tend not to use grassland, and are

more generally confined to the coast.

5.5.4. However, as outlined within the Bird Hazard Control Plan (see Appendix 5),Manston Airport currently implements grass management according to the LongGrass Policy outlined within CAP 772: Birdstrike Risk Management forAerodromes, thus keeping the grass at a sward height between 150mm and250mm throughout the year, and any balancing ponds are covered by metalgratings. This management regime, which is to continue following theimplementation of the proposed Night-time Flying Policy, will continue to keep grassand open water habitats in the vicinity of the airport less attractive to birds such asGolden Plover, and therefore minimise the risk of collision.

5.5.5. Birds are also actively chased off from the runways and high risk zones around theairport to further reduce the chances of collision. During the day- time this procedureinvolves a number of techniques including bird-scaring cartridges and broadcastingdistress calls, however at night due to the low visibility and additional risk factorsinvolved, the normal chasing technique involves the use of vehicles headlights tocarefully herd birds off the areas most at risk.

5.5.6. The use of the above techniques to minimise bird strike risk as outlined withinManston Airports Bird Hazard Control Plan appears to be effective at controlling thenumber of bird strikes, as only a very small number of bird collisions (3 and 5respectively) were recorded by the airport in 2010 and 2011 (significantly fewer thanthe average for other UK airports), and of these, none were Golden Plover. Given

the relatively low bird strike rate at Manston Airport, and the absence of anyrecorded Golden Plover collisions, it is considered unlikely that the proposed night-time flights would pose a significant collision risk to Golden Plover.

5.5.7. Although the majority of recorded collisions of birds with aircraft are understood to


19/111



take place within the immediate vicinity of the airport, the possibility remains thataircraft departing, or coming in to land at the airport may intersect with individualbirds, or nocturnally migrating / moving flocks along the coastline and/or inlandtowards favoured foraging grounds.

5.5.8. There is currently a preferred runway usage strategy in operation at Manston

Airport, which seeks to avoid the most dense area of human settlement to the eastof the airport. Consequently, a significant proportion of approach and departure lineslie towards the east and north, over Thanet Coast and Sandwich Bay SPA/Ramsar,and Thanet Coast SAC in particular. A review of available data indicates thatthese flight paths coincide with areas of habitat supporting moderate to highpopulations of Golden Plover, Turnstone and Little Tern, (see Plan 2995/ECO4) andevidence (pers. comm. Pete Findley) suggests that the majority of local wader flight-lines / migration routes also cross these areas, particularly at key times of year(autumn/winter and spring). The use of such flight-lines and migration routesby relevant species, is known to often occur at night.

5.5.9. There is very little information within the available literature pertaining to normal or

migratory flight altitudes of specific bird species. Nevertheless, a number ofdocuments suggest that the majority of coastal migratory birds, including those thatmigrate or move at night, will ordinarily not travel above 2,000m, and that thegreatest proportion of birds will generally travel below 200m (O. Hppop, 2006; andB. Bruderer, 2004).

5.5.10. General advice provided by the Civil Aviation Authority recommends that In order tolessen the risk of bird strikes, pilots of low flying aircraft should, whenever possible,avoid flying at less than 1,500ft {approximately 457m} above surface level overareas where birds are likely to concentrate. Information obtained from ManstonAirport indicates that, on average, when aircraft arriving or departing from Manston

Airport intersect with the coast under the current flying regime, they are travelling atan altitude of 2,534m, i.e. above the maximum altitude of 2,000m that birds willordinarily fly at, and well above the 200m that the large majority of waders generallyfly below (K. Exo, 2003). However, when aircraft are arriving at Runway 28,travelling over Thanet Coast and Sandwich Bay SPA / Ramsar and Thanet CoastSAC, they tend to be at a lower altitude, with the minimum altitude recordedwithin the data provided being 450m. Nonetheless, this altitude is still well abovethe typical flight heights of most waders, and approximately accords with the CivilAviation Authoritys recommendations of aircraft not flying below 457m above areaswhere birds are likely to concentrate.

5.5.11. Although the frequency of flights overnight could increase following the

implementation of the proposed Night-time Flying Policy, the flight lines andaltitudes of aircraft will not be altered. Accordingly, the majority of aircraft willremain above the altitudes at which they are most likely to encounter birds such asthe Golden Plover, Turnstone or Little Tern. In summary, the collision risk posed bythe Night-time Flying Policy is minimal, and it is therefore extremely unlikely to resultin any significant effects on the qualifying SPA bird species.


5.5.12. Birds are known to be sensitive to noise disturbance to varying degrees, and theeffects of noise on birds range from physiological changes including permanenthearing damage, masking of bird song / calls affecting breeding success, and

behavioural changes including reduced food intake, increased energy expenditure,and the reduction of habitat suitability to such an extent that birds will avoid areasentirely (R.S. Dooling, 2007 and A. Drewitt, 1999). Birds will often becomehabituated to noise when they are regularly exposed to it, however, more


20/111



infrequent noise events, particularly at higher dB levels, will generally result in moremarked disturbance effects / behaviour.

5.5.13. Aircraft are known to disturb birds such as Golden Plover, Turnstone and Little Tern,albeit none of these species are thought to be particularly susceptible to disturbance(N. Deacan, 2010), and there appears to be no current evidence that noise-induced

disturbance leads to population-level impacts in these particular species. It is difficultto determine how much of the disturbance caused by aircraft is due to noise, andhow much is caused by visual stimuli. The literature available does suggest that atleast some disturbance is caused by visual cues, for example where aircraft may bemistaken for birds of prey (A. L. Brown, 1990), however it is considered likely that, inthe case of larger commercial aircraft, noise is the greater contributory factor. In anycase, logically, any response to visual stimuli should be lessened overnight, as theaircraft outline will be less visible.

5.5.14. As outlined in section 5.5.8, a large proportion of aircraft flight-paths lie over ThanetCoast and Sandwich Bay SPA/Ramsar, and Thanet Coast SAC, and coincide withareas of habitat within these sites supporting moderate to high populations of

Golden Plover, Turnstone and Little Tern.

5.5.15. Information provided by Manston Airport indicates that from 0 100m altitude(the range of altitudes at which birds will be stationary or slow moving, and thereforelikely be most susceptible to disturbance effects), the predicted noise levels fromindividual aircraft passes at the coast, where the greatest numbers of each of thesespecies forage and roost, will be between 43 and 80dB(A) SEL (Single Event Level).

5.5.16. Little information is available pertaining to specific dB limits that are consideredharmful to birds, partly because the effect of noise on birds varies greatly betweenspecies. Nevertheless, the literature available suggests that on average, a

continuous noise 93dB or above can cause temporary hearing loss in birds, whilstcontinuous noise below this level may still cause masking of other bird calls, andpotentially behavioural and/or physiological responses (R. J. Booling, 2007).Similarly, single noise events (such as those produced by over-flying aircraft) at alevel above 85dB, have been shown to precipitate escape or startle responses (A. L.Brown, 1990). Available literature suggests that these responses would beincreased in the case of low-flying helicopters and ultra-lights (A. Drewitt, 1999) andwhere unpredictable, curving flight lines are utilised, as this prevents habituation.

5.5.17. In the case of aircraft at Manston Airport, the frequency of flights overnight under theproposed Night-time Flying Policy would be relatively low (predicted 2 flights pernight5), and certainly any noise resulting from these flights that reaches nearby bird

colonies could not be considered continuous. Furthermore, even if the noise levelwere continuous, the highest predicted dB level at the coast is 13dB lower than thedB level suggested to cause temporary hearing loss in birds, and therefore physicalharm such as this is extremely unlikely to occur. The predicted dB level is also 5dBlower than the noise level that has been shown to precipitate escape or startleresponses. The possibility remains that some time-limited masking (i.e. where theaircraft noise is louder than the birds calls, thus disrupts communication) andbehavioural and physiological responses may still be caused by this noise level,however in relation to night-time flying, this will be limited to very infrequentdisturbance and is therefore considered unlikely to result in any significant effect onpopulations of qualifying bird species.



21/111



5.5.18. It is also relevant to note that the proposed Night-time Flying Policy applies to analready operational airport with birds already exposed to over-flying aircraft. Assuch, it is likely that birds will already be habituated to existing aircraft noise to adegree, and although not direct evidence of habituation, it is noted that bird numbersat the SPA have remained relatively stable over the last 5 years.

5.5.19. Given that noise levels are below those likely to precipitate escape or startleresponses, night-time noise will generally be limited to an anticipated average of 2flights per night (amounting to a low frequency) and the birds will already behabituated to aircraft movements, it is concluded that noise disturbance from night-time flying alone, or indeed in combination with day-time flights, is unlikely to haveany significant effect on the populations of qualifying SPA bird species.

Light disturbance

5.5.20. Lighting, at the relatively low levels that will be involved at Manston Airportovernight, is unlikely to directly affect birds such as Golden Plover, Turnstoneand Little Tern, and indeed at the coast will have negligible effect.

5.5.21. Golden Plover forage on invertebrates, many of which are known to be attracted byrunway lights (G. F. van-Tets, 1969), and an increase in the frequency at whichthese lights are turned on overnight might marginally increase the population ofsuch invertebrates within the surrounds of the airport. An increase in suchpopulations may, in turn, increase the risk of collision of aircraft with any GoldenPlover that are attracted by this additional foraging resource. However, given theBird Hazard Control Plan will continue to function under the proposed Night-timeFlying Policy, it is considered that the slight increase in frequency of the run-waylights being turned on (for up to approximately 2 flights per night6), will notsignificantly increase either the population of invertebrates, or the risk of collision of

aircraft with Golden Plover.

Non-toxic contamination by organic and/or nutrient enrichment (e.g. Atmosphericpollution)

5.5.22. As outlined within the assessment in section 5.3, aircraft emissions are known tolead to nitrogen deposition, which in turn can lead to changes in the composition ofaffected habitats through processes such as eutrophication. Should this occur to thehabitats supporting birds such as Golden Plover, Turnstone and Little Tern, theforaging resources, breeding success and survival could be harmed in the longterm.

5.5.23. However, as described in more detail in section 5.3, the increase in the total numberof flights that will occur is minimal, and accordingly any increase in pollutants willalso be very limited. As set out in section 5.4, DEFRA Guidance states that beyondthe distance of 1km from the source, NO2 is unlikely to make a significantcontribution to air quality. Accordingly (extrapolating guidance for NO2 to allrelevant oxides of nitrogen [NOX]) given that the source of potential pollution atManston Airport lies 1.27km away from the nearest part of the SPA, in line with thisguidance, it is considered unlikely that any significant effects will arise on the SPA inrespect of NOx emissions and resultant N deposition caused by the proposedincrease in flights at Manston Airport.

5.5.24. Further confidence in this assessment is provided by the passenger equivalent per

annum for Manston Airport in 2018 falling well below the threshold described withinthe DEFRA Guidance and set out in more detail within sections 5.3 and 5.4, in



22/111



addition to APIS predictions in regard to the anticipated future reductions inindividual aircraft emissions.

Toxic contamination by increased input of synthetic and/or non-syntheticcompounds (e.g. Surface run-off)

5.5.25. The surface water run-off from Manston Airport currently discharges into PegwellBay (see Appendix 4), and contains low concentrations of a number ofsynthetic and non-synthetic compounds. These pollutants have the potential tonegatively impact upon birds such as Golden Plover, Turnstone and Little Tern viaaccumulation through the food-chain affecting breeding success, and more indirectlythrough harming the ecology of habitats supporting these species.

5.5.26. However, the proposed Night-time Flying Policy will not result in a net increase inthe volume or concentration of surface water pollutants, and in any event, theexisting surface water discharge is planned to be either intercepted or relocated to aless sensitive area near the airport, and away from the Thanet Coast and SandwichBay SPA. It is therefore considered unlikely that surface water discharge resulting

from the new Night-time Flying Policy will significantly affect the Thanet Coast andSandwich Bay SPA.

Biological disturbance as result of selective extraction of species

5.5.27. As outlined above, the airport is geographically well separated from all the ThanetCoast and Sandwich Bay SPA and will not directly impact upon it. As such, theadditional flights resulting from the proposed Night-time Flying Policy will not resultin any biological disturbance as a result of selective extraction of species.

Increased road traffic

5.5.28. The new Night-time Flying Policy will likely result in a small increase in road trafficvolume, however this increase will be minimal, and accordingly any negative effecton the species and habitats within the SPA will be negligible, especially given thatthe existing road network associated with access to the airport is located away fromthe SPA.

Summary

5.5.29. In summary, the above assessment demonstrates that it is unlikely that the Night-time Flying Policy will have any significant effect upon the habitats and specieswithin Thanet Coast and Sandwich Bay SPA.

5.6. Analysis of Potential Impacts on the Thanet Coast and Sandwich Bay Ramsarunder the proposals

5.6.1. The potential effects of disturbance, including noise, visual and light, and the otherpotential impacts such as collision risk and pollution, on birds including Turnstone,are described and analysed in detail within section 5.5. Sections 5.3 and 5.4 alsoassess, in detail, the potential effects of pollution on habitats within the Ramsar, andtherefore the potential effects on the qualifying invertebrate species that directly relyupon these habitats. In summary, it is considered unlikely that the proposed Night-time Flying Policy will have any significant effects upon the Ramsar.

5.7. In Combination Assessment

5.7.1. As described in detail within this assessment, the likelihood of the implementation ofthe proposed Night-time Flying Policy at Manston Airport having a significant effect


23/111



with regard to physical loss / damage of the relevant habitats, biological disturbance,increased road traffic, pollution within surface water run-off, light disturbance andcollision with aircraft is negligible, and there are no known proposals, including theoverall Masterplan for Manston Airport, that would appear likely to combine with theminimal effects predicted from the proposed Night-time Flying Policy in such a wayas would result in likely significant effects on Thanet Coast / Sandwich Bay SACs, or

Thanet Coast and Sandwich Bay SPA / Ramsar.

5.7.2. Furthermore, as set out in sections 5.3 5.5, DEFRAs Technical Guidance onLocal Air Quality Management states, in respect of NO2, concentrations fall-offrapidly on moving away from the source, and that beyond a distance of 1km fromthe source, NO2 is unlikely to make a significant contribution to air quality.Accordingly (extrapolating guidance for NO2 to all relevant oxides of nitrogen[NOX]) given that the sources of potential pollution at Manston Airport (i.e. therunways) lie at least 1.27km away from the nearest part of the relevant ecologicaldesignations, in line with this guidance, it is considered that any air quality effectsfrom aircraft at Manston Airport (i.e. from either the Night-time Flying Policy alone orin combination with the proposed day-time flights under the Masterplan) on relevant

habitats and species are unlikely to be significant.

5.7.3. Finally, implementation of the proposed Night-time Flying Policy at Manston Airportis unlikely to have any significant effect with regard to noise and visual disturbanceof qualifying bird species, and the proposed night-time flights are unlikely to add tothe effect of any additional day-time flights, as these would occur at times of the dayduring which regular flights already take place, and to which birds are already likelyto be habituated. There are no other known proposals incorporating additional night-time flights within the vicinity of Manston Airport.

5.7.4. In summary, there are no known proposals, including the Masterplan for Manston

Airport, that would appear likely to combine with the minimal effects predicted fromthe proposed Night-time Flying Policy in such a way as would result in any likelysignificant effects on Thanet Coast / Sandwich Bay SACs, or Thanet Coast andSandwich Bay SPA / Ramsar.

5.8. Summary of Predicted Effects on the European Designations

5.8.1. For convenience, a summary of the above assessment is provided in Table 2 below.


24/111



Table 2. Summary of predicted effects resulting from implementation of the proposed

NTFP and likely significance on nearby ecological designations


25/111



5.9. Conclusion of the Habitats Regulations Assessment

5.9.1. Based on the results of the above screening assessment, taking account of thenature, magnitude and scale of the proposals along with the stated conservationobjectives and known sensitivities of the habitats and species associated with theThanet Coast SAC, Sandwich Bay SAC and Thanet Coast and Sandwich Bay SPA /Ramsar, it is concluded that the proposed Night-time Flying Policy is unlikely to leadto any significant effects on the relevant internationally important interest features.As such, it is considered that no further detailed consideration of the proposals by

the Competent Authority is required under the Habitats Regulations.


26/111



6. REFERENCES

Anderson, B. E. et al. (2006): Hydrocarbon emissions from a moderncommercial airliner, Atmospheric Environment, 40:19, 3601 3612

Brown, A. L. (1990): Measuring the effect of aircraft noise on sea birds,

EnvironmentInternational, 16, 587-592

Bruderer, B. & Liechti, F. (2004): What proportion of migrating birds flies in theheight zone of wind turbines?, 101, 327-335

Deacon, N. & McLellan, M. (2010): The Relationship Between CommercialAirport Operations and the Bird Populations of Adjacent Wetlands in the UnitedKingdom, MMX Environmental Practice

Dooling, R. J. & Popper, A. N. (2007): The effects of Highway Noise on

Birds, Environmental BioAcoustics LLC

Drewitt, A. (1999): Disturbance effects of aircraft on birds, English Natureinternal report

Exo, K-M. (2003): Birds and offshore wind farms: a hot topic in marineecology, Wader Study Group Bull., 100, 50-53

Hppop, O. et al. (2006): Bird migration studies and potential collision riskwith offshore wind turbines, 148, 90-109

Rochard, J. B. A. & Horton, N. (1980): Birds killed by aircraft in the UnitedKingdom,1966-76, Bird Study, 27:4, 227 234

Van-Tets, G. F. (1969) Orange runway lighting as a method for reducing bird strikedamage to aircraft, CSIRO Wildlife Research, 14, 129-15


27/111

PLANS


28/111

PLAN 2995/ECO1

Site Location


29/111

Based upon the Ordnance Survey map with permission of the Controller of Her Majestys Stationery Office, Crown Copyright. Aspect Ecology Ltd . Licence No. 100045262, West Court, Hardwick Business Park, Noral Way, Banbury, Oxfordshire, O 16 2AFX


30/111

PLAN 2995/ECO2

Ecological Designations


31/111

Based upon the Ordnance Survey map with permission of the Controller of Her Majestys Stationery Office, Crown Copyright. Aspect Ecology Ltd . Licence No. 100045262, West Court, Hardwick Business Park, Noral Way, Banbury, Oxfordshire, O 16 2AFX

BISHOPSTONE CLIFFS LNR

THANET COAST & SANDWICH BAY RAMSAR/SPA

THANET COAST SAC/SSSI

PRINCES BEACHLANDS LNR

SANDWICH & PEG

SANDWICH BAY TO HACKLINGE MARSHES SSSI

THANET COAST & SANDWICH BAY RAMSAR/SPA

SANDWICH B

SANDWICH BAY TO HACKLINGE MARSHES SSSI


32/111

PLAN 2995/ECO3

Distribution of Qualifying Bird Species


33/111

B as ed up on the O rdn an ce Sur vey m ap wit h pe rmi ssi on o f t he C ont rol ler of H er Ma je st y s S tat ion er y O ff ice , C ro wn C opy rig ht. A sp ec t E col og y L td . Li ce nc e N o. 1 000 45 262, West Court, Hardwick Business Park, Noral Way, Banbury, Oxfordshire, OX16 2AF

KEY:

REV.

PROJECT

TITLE

DRAWINGNO.

DATE

2995/ECO3

DISTRIBUTION OF QUALIFYINGBIRD SPECIES

MANSTON AIRPORT,NIGHT-TIME FLYING

AUGUST 2012N

Aspect Ecology Limited - West Court - Hardwick Business ParkNoral Way - Banbury - Oxfordshire - OX16 2AF

01295 276066 - [email protected] - www.aspect-ecology.com

SITE LOCATION

WeBS SURVEY SITE

Peak number of individuals duringpeak season -less than or equal to 10

GOLDEN PLOVER

TURNSTONE

LITTLE TERN

Peak number of individuals duringpeak season -between 11 and 100


Peak number of individuals during

peak season -greater than or equal to 1001

Westbrooke

Walpole Bay & Palm Bay

KEY:

HIGH DENSITY -greater than 5.0birds per Ha

MEDIUM DENSITY- between 2.0 and5.0 birds per Ha

LOW DENSITY- less than 0.1birds per Ha

GOLDEN PLOVER

TURNSTONE


MEDIUM DENSITY- between 0.2 and

5.0 birds per Ha

Pegwell Bay

North Foreness to North Foreland

Broadstairs and Ramsgate

Minnis Bay to Reculver


34/111

PLAN 2995/ECO4

Aircraft Flight Paths


35/111

B as ed up on the O rdn an ce Sur vey m ap wit h pe rmi ssi on o f t he C ont rol ler of H er Ma je st y s S tat ion er y O ff ice , C ro wn C opy rig ht. A sp ec t E col og y L td . Li ce nc e N o. 1 000 45 262, West Court, Hardwick Business Park, Noral Way, Banbury, Oxfordshire, OX16 2AF

KEY:

REV.

PROJECT

TITLE

DRAWINGNO.

DATE

2995/ECO4

AIRCRAFT FLIGHT PATHS

MANSTON AIRPORT,NIGHT-TIME FLYING

AUGUST 2012N

Aspect Ecology Limited - West Court - Hardwick Business ParkNoral Way - Banbury - Oxfordshire - OX16 2AF

01295 276066 - [email protected] - www.aspect-ecology.com

SITE LOCATION

WeBS SURVEY SITE

Peak number of individuals duringpeak season -less than or equal to 10

GOLDEN PLOVER

TURNSTONE

LITTLE TERN



Peak number of individuals duringpeak season -greater than or equal to 1001

PLANE ARRIVAL FLIGHT LINE

PLANE DEPARTURE FLIGHT LINE

Westbrooke

Walpole Bay & Palm Bay

KEY:


MEDIUM DENSITY- between 2.0 and5.0 birds per Ha

LOW DENSITY- less than 0.1birds per Ha

GOLDEN PLOVER

TURNSTONE


MEDIUM DENSITY- between 0.2 and

5.0 birds per Ha

Pegwell Bay

North Foreness to North Foreland

Broadstairs and Ramsgate

Minnis Bay to Reculver


36/111

APPENDICES


37/111

APPENDIX 1

Manston Airports Night-time Flying Policy


38/111

Manston Airport - page 1 - 27 October 2011

Proposed Night-time Flying Policy

Manston Airport Proposed Night-time Flying PolicySubmitted to Thanet District Council 27 October 2011

Background

1. In 2009, following the potential start of dedicated cargo operations by British Airways WorldCargo, Thanet District Council (TDC) requested Manston Airport (MSE) to develop and

submit to the council a Night-time Flying Policy (NTFP) pursuant to clauses 1.2 and 1.3 of the

Second Schedule to the Section 106 agreement dated 26 September 2000 between TDC and

MSE. An initial outline was presented on 17 August 2009, which was subsequently further

developed, with a full submission being made on 28 September 2010.

2. TDC considered this proposal and commissioned a technical review from Bureau Veritas. Asa result TDC have asked the airport to reconsider and provide further information on various

aspects of the proposal. This has now been undertaken and the proposal contained herein is

now submitted for the Councils consideration.

3. For airports to prosper and fulfil their potential in stimulating economic activity, they mustbe in a position to serve the needs of the markets in which they operate. Equally important,

the operation and development of an airport must be acceptable to the resident and

business communities within which they are located.

4. Clearly the issue of night-time noise is significant for residents in close proximity to theairport. This is the reason that many airports have specific policies governing, and

sometimes limiting, their night-time activity.

Section 106 Agreement

5. The agreement between TDC and the airport which governs the permitted activity of theairport was entered into in 2000. In respect of night-time flying it sets out the limitations on

such operations until a Night-time Flying Noise Policy is in place. Clause 1.1 of the Second

Schedule states:

The Owner agrees not to cause suffer or permit any Regular Night Flying Operations

at any time (subject to Paragraph 1.4 below) before a Night-time Flying Noise Policy

shall have been prepared and a copy lodged with the Council.

6. Further, it defines:Regular Night Flying Operation means Flight movements which are scheduled or

programmed and which occur frequently or

regularly to the same or similar patterns for the

same operator during Night-time


39/111



Master Plan

7. National Aviation Policy is set out in the Future of Air Transport White Paper (FATWP)published in 2003. The key strategic policy established was that most effective use should

be made of existing runways, in order to delay or remove the need to construct new

runways, or indeed airports. On taking office in 2010 the Coalition Government stated thatnew runways would not be built at any of the three major London airports Heathrow,

Gatwick or Stansted. This decision has strengthened the case to make best use of existing

runway capacity as growing demand for air travel and transport will need to be

accommodated within existing runway capacity. This national policy further increases the

prospects for future demand at Manston.

8. Amongst the requirements contained in the FATWP was that for airports to produce MasterPlans for their development over the following 25 years. These are to be used by local and

regional planning authorities to inform the development of planning policy. Manston

Airport, then trading as Kent International Airport, published its draft Master Plan for

consultation in October 2008. Following a wide-ranging public debate, with commentsreceived from many interested parties, notably TDC, the final Master Plan was published in

November 2009, taking account of the points raised.

9. TDC has, at full council, received the Master Plan and resolved that in due course officers willprepare supplementary planning guidance regarding the airport.

10. The Master Plan lays out the prospects for traffic growth at Manston Airport, together withthe potential land use developments needed to accommodate this increase in activity. It

also identifies the economic impacts that such growth may be expected to bring.

2010 2018 2033Passengers


40/111



13. The graph below shows the monthly record of movements from January 2009 to September2011, compared with the level of night-time activity between 2300 and 0700, and between

2330 and 0600. In the 12 months to September 2011, a total of 43 aircraft movements were

recorded between 2300 and 0700, of which 31 occurred between 2330 and 0600.

14. Today some 110 staff are employed by the airport, with approximately a further 40employed in servicing the operation of the airport in areas such as aircraft engineering,

flying schools and catering to passengers. In addition another 100 people are employed inaviation related businesses and with airport tenants.

15. Of the airports direct employees the majority live in Thanet, with the reminder living mostlyin East Kent. This is a usual feature of airport employment, where shift working is the norm

and main employment is for semi-skilled labour. The annual payroll for the airports

employees is in excess of 2.2m pa, two thirds of which is paid to residents of Thanet. In

itself, this makes a substantial contribution to the local economy.

0

5

10

15

20

25

30

0

100

200

300

400

500

600

Jan-0

9

Mar-09

May-0

9

Jul-09

Sep-0

9

Nov-0

9

Jan-1

0

Mar-10

May-1

0

Jul-10

Sep-1

0

Nov-1

0

Jan-1

1

Mar-11

May-1

1

Jul-11

Sep-1

1

TotalNighttimemovementspermonth

TotalCommercialMovementspermonth

Commercial Movements per month 2009 to 2011

Total Movements 2300-0700 Total Movements 2330-0600 Total Commercial Movements


41/111



16. The distribution of employment within Thanet is shown on the map below (by postcode).This demonstrates that the key employment areas are CT12, CT9 and CT11. Given that the

growth of employment as the airport develops will be of the same broad characteristics, it is

reasonable to predict that these areas too will provide the bulk of the new employees.

17. The airport is committed as far as possible to recruiting from the local labour market. Italready places all external vacancy notices with JobCentre Plus. For future development, it

has contacted with Christ Church University, Thanet College and Employ Thanet with a view

to establishing a programme that identifies the skills needs for the newly created job

opportunities, and delivers suitable training to local people allowing them to access these

posts as they become available. It is fundamental to the success of Manston, as with other

airports, to have a local and flexible labour force able to respond to the changing needs of

airlines and passengers.

66%27%

5% 1% 1%

Manston Airport EmployeesAugust 2011 by postcode

Thanet (CT7 - 12)

Other CT postcodes

ME

TN

Other

CT7

1.9%

CT8

4.8%

CT9

17.1

CT10

8.6%

CT11

13.3%

CT12

20.0%


42/111



18. Procurement policies at Manston seek, wherever possible to source goods and services fromlocal suppliers. Excluding fuel purchases, over 12 months in 2010 and 2011 external

procurement amounted to over 1m. Of this more than 64% was sourced within Kent, with

22% locally in Thanet.

Economic Value of Manston Airport

19. Manston Airport has commissioned a study of the economic impact of the airport within thelocal economy Manston Airport, Economic Impact of Night Flying Policy, August 2011 .

This report, carried out by York Aviation LLP, recognised authorities in the economic

assessment of aviation, identified the operational activity of the airport currently generated

4.5m GVA (Gross Added Value) of which some 3.8m is within the Thanet economy. A copy

of this report is supplied with this submission.

20. The study further assessed the impact of development in line with the published MasterPlan, showing that, at the 2018 traffic levels, the airpo rts operation would support direct

employment of over 2000 jobs, with a further 1000 indirect and induced in the wider

economy. This level of employment would generate 65m GVA.

21. The substantial growth in airport activity and through this in economic benefit inemployment and GVA will come from attracting airlines to base aircraft to operate from

Manston. Such aircraft will offer multiple services each day to a variety of destinations,

serving a range of different market needs. With this activity will come a wider range of

employment opportunities, including flight crew (pilots), cabin crew, aircraft engineering

support, station and general management.

22. Also assessed in the report was the impact of the imposition of a ban on scheduled trafficbetween 2300 and 0700. The report assessed the impact that such an imposition would

have on the ability of the airport to attract new business and in particular to secure an

airline to base aircraft at Manston. It considered that, given the likely impact on the

flexibility of operation, such a ban would have a severe restraint on the ability of the airport

22%

12%

23%7%

36%

Manston Airport Procurement2010/11 by postcode

Thanet (CT7-12)

Other CT

ME

TN

Other


43/111



to develop both in the passenger and the cargo sectors. The consequent loss of economic

activity generated by the airport would amount to 30m GVA and some 1450 jobs lost.

23. The report also commented on the impact that this limit on night-time operations wouldhave on the financial viability of the airport. It noted that

if the Airport cannot

habitats regulations screening assessment - oct 2012

Documents